NCGA COMMENTS ON PROPOSED RFS PATHWAYS AND STANDARDS

JULY 2013

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(Posted Fri. Jul 12th, 2013)

July 12: The National Corn Growers Association submitted comments in the form of a letter from President Pam Johnson today to the U.S. Environmental Protection Agency on the “Regulation of Fuels and Fuel Additives: Renewable Fuel Standard Pathways II and Technical Amendments to the RFS 2 Standards.” In these comments, NCGA addresses EPA’s requests for comments on sections of the Agency document addressing approving cellulosic volumes from cellulosic feedstocks, proposed regulatory amendments related to biogas, amendment to the definition of ‘‘crop residue’’ and definition of a pathway for corn kernel fiber, and consideration of an advanced butanol pathway.

The letter begins by detailing the important benefits that corn ethanol offers the nation in terms of its economic and energy security. Explaining how growers are meeting the demand for corn in a sustainable manner, it notes the importance of ethanol to our environment and the greenhouse gas reductions it continues to accomplish. It also commends the Agency on the proposed rule, on its recognition of the benefits of ethanol in transportation fuel, and its continued support for the Renewable Fuel Standard regulation.

“This level of ethanol production for fuel represents 10 percent of the nation’s gasoline supply that can be found in more than 96 percent of all gasoline sold. There are many benefits of ethanol in the fuel supply including, but not limited to: improved energy security, reduced greenhouse gas emissions, reduced oil imports, reduced gasoline prices, and thousands of U.S. jobs, just to name a few. NCGA’s members remain committed to providing this important source of energy for U.S. drivers. The corn crop will also play an important role in the future, providing feedstock for cellulosic ethanol and animal feed supplements, through the use of millions of tons of available corn stover.”

Then, the comments address the specific areas on which the Agency requested comments from NCGA.

The letter concluded saying, “In summary, we feel that: 100 percent of the volume of renewable fuel from specific cellulosic feedstock sources should be allowed to generate D3 or D7 RINS as appropriate, all biomass feedstock sources be renewable, the definition of crop residue should not be modified, corn kernel fiber should be included as a crop residue and counted towards D3 RINS, butanol be included as a new pathway for advanced RINs and be allowed to be commingled with ethanol and be considered in compliance with existing RVP standards. Thank you for the opportunity to comment on the Regulation of Fuels and Fuel Additives: RFS Pathways II and Technical Amendments to the RFS 2 Standards.”